Golden State Transit Corporation v. City of Los Angeles

Introduction

Golden State Transit Corporation d/b/a Yellow Cab of Los Angeles (Yellow Cab) brought this action against the City of Los Angeles (City) when the City refused to renew Yellow Gab’s taxicab franchise. Yellow Cab sought a preliminary injunction and moved for partial summary judgment contending that the City committed a per se violation of section 1 of the Sherman Act, 15 U.S.C. § 1 . The district court denied both requests and instead granted the City a partial summary judgment dismissing Yellow Cab’s antitrust claim. The district court based both decisions on its conclusion that the City was protected from antitrust liability by the Parker doctrine. Parker v. Brown, 317 U.S. 341 , 63 S.Ct. 307 , 87 L.Ed. 315 (1943).

Procedural History

In 1981, when Yellow Cab filed this action against the City, it did not allege antitrust violations. Instead, it alleged that the City’s refusal to renew its taxicab franchise violated the Supremacy Clause and also deprived it of due process and equal protection of the law in violation of 42 U.S.C. § 1983 . In that proceeding, the district court granted a preliminary injunction which prevented the City from terminating Yellow Cab’s…